Standard Interpretations - Table of Contents
• Standard Number: 1910.178

June 28, 2004

Mr. Travis Morenz
PM- Inventory Control Supervisor
Horizon Hobby, Inc.
4105 Fieldstone road
Champaign, IL 61822

Dear Mr. Morenz:

Thank you for your April 13 letter to the Occupational Safety and Health Administration (OSHA) regarding the use of body belts and the harnesses on elevated platforms of powered industrial trucks. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any questions not delineated within your original correspondence. Your paraphrased questions and our responses are provided below:

Question 1: In regards to the use of fall arrest equipment and the use of body belts, do OSHA regulations require that a body belt be attached to a lanyard and used to protect personnel against falls from elevated "operator-up" high lift truck platforms, or do the standards state that a 5-point harness must be worn as a part of a fall arrest device?

Response: OSHA's powered industrial trucks (PITs) standard, contained in 29 CFR 1910.178, does not have provisions that require either the use of a body harness or safety belt to protect personnel against falls from elevated platforms. However, in the absence of a specific standard, OSHA can enforce Section 5(a)(1) of the Occupational Safety and Health Act (OSH Act) -- which requires employers to protect employees from serious recognized hazards. Industry consensus standards, such as ASME B56.1-2000 Safety Standard for Low Lift and High Lift Trucks would be taken into consideration by OSHA when determining whether a hazard is "recognized" and that there is a feasible means of abating such a hazard. Section 4.17.2(c) of ASME 56.1-2000 requires that whenever an operator-up high lift truck is used to elevate personnel, restraining means such as rai